Page 1 of 23 NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ANL-E Finding 1 

2/13/2017

Status = Open

Potential Missed Dose from Lack of Definition of Radionuclide Compositions and Radionuclides Not

Addressed in Site Profile 

Hughes, Lara, 3/8/2017

The TBD does not specify uranium mixture values for enriched and depleted uranium for several

reasons. Research on uranium composition is still underway. Meanwhile, bioassay results record

uranium in units of mass (typically micrograms/1500mL or per sample) or activity (dpm/1500mL

or per sample). Unless otherwise specified, uranium would be assumed to be natural uranium,

with mass or activity units typically reported. If work with enriched uranium is involved, bioassay

records are noted ‘U-235’ and results are reported as activity (SRDB 165264 pg 59-64).

The TBD currently provides two plutonium mixtures, one to be used for materials received from

New Brunswick Laboratory and the other considered to 'bound' risks at ANL-E. The TBD 

currently provides direction to dose reconstructors on use of these mixtures. As the finding notes,

ANL-E is a research (not a production) facility, so a diversity of materials may have been

encountered, consequently, it is unlikely that a specific set of mixtures can be identified as

representative of typical operations. Plutonium bioassay results may be recorded as ‘Pu’ or for the

specific plutonium isotope (e.g., Pu-239, Pu-238).

Americium composition, as part of a plutonium mixture, may be inferred from the assumed age of

the material using current methods. Specific americium identified in a bioassay monitoring record

would identify exposure to isolated americium (i.e., not part of a plutonium mixture) and the

isotope involved, which would typically be Am-241.

Review of early records demonstrate that, while the bulk of bioassay monitoring indicated work

primarily with natural uranium, specific bioassay analyses were performed as needed based on the

radionuclide involved (see for example Bioassay Program Reports in SRDB 165264, with specific

analysis for polonium in 1949 (pg 19), radium in 1950 (pg 20), neptunium related to a spill in

1960 (pg 32), and individual radium and thorium isotopes related to an intake incident (pg 56)). 

Buchanan, Ron, 7/16/2017

SC&A finds that the current TBD-5, ORAUT-TKBS-0036-5, Revision 00, of March 2006, does

not provide adequate coverage of the many different radionuclides that potentially were present at

a research lab, such as the percent enrichment of uranium, accelerator-produced radionuclides, and

exotic radionuclides. The ability and knowledge needed to monitor for the many possible

radionuclides present, especially in the early years, is likely questionable for ANL-E, as it was for

other research facilities in the U.S. Department of Energy (DOE) complex at that time. See

attachment for details. 

Attachments: 

●Finding_No._1_ANL-E_Radionuclides_by_SCA_2009.docx

Lobaugh, Megan, 2/9/2018

For a research facility with the broad range of activities that were in existence at ANL-E,

identifying a “routine” enrichment value for enriched uranium or a site-wide mixture ratio for

plutonium isotopes would not be expected. Research into ANL-E records indicates a variety of

radionuclides in addition to uranium and plutonium were encountered, and bioassay procedures

were implemented to monitor the specific radionuclides from early periods of operation. Records

show that analysis results for at least 34 individual radionuclides were included in bioassay

analytical reports from 1953 through 1976. 

NIOSH acknowledges the difficulty this presents in performing dose reconstructions on mixtures

of radionuclides, however, assumptions can be made to allow reasonable and claimant favorable

assessments (see below). 

Uranium in the workplace was typically in the form of natural uranium, based on the numerous 

Argonne National Laboratory (East) Work Group Board Review System (BRS) Discussions
Page 2 of 23

bioassay results found, which is adequate to develop dose reconstructions in the majority of claims

(and which overestimates the dose if the results are not in units of activity and the mixture is

depleted uranium that is not noted in the records). Work with enriched forms of uranium is 

documented in monthly reports and bioassay records from early periods, although the degree of

enrichment was not generally provided for individual activities and was likely variable depending

on the project. Additional records obtained since the previous TBD revision include typical

enrichment values for medium and high enriched uranium with the highest recorded value of 93%

U-235 (e.g. SRDB Ref. ID 108979, pg. 79-80). This value may be used to derive specific

activities for individual uranium isotopes that can be used as bounding estimates for the few cases

where enriched uranium is encountered and results are not in units of activity. This may result in

high positive or missed doses for a limited number of cases. 

The TBD currently lists two specific plutonium mixtures from a 1979 Draft Environmental Impact

Statement, both of which are described as bounding typical risks for ANL-E operations. Five

additional ratios, described as representing “assumed adverse cases,” are listed in SRDB Ref. ID

44149 (1975), pg. 34-36. It is not noted whether these mixtures are representative of actual

operating conditions, but the ratios are similar to those currently in the TBD. Finally, SRDB Ref.

ID 90471 (1966) describes a typical ratio content of plutonium used for the Zero Power Plutonium

Reactor (ZPPR) fuel fabrication operations, with somewhat higher Pu-239 content relative to the

other constituents. Again, given the diversity of ANL-E projects, it is not anticipated that an exact

ratio will be available for each operation, but in the absence of specific information, it appears that

adequate bounding assumptions can be made from the current TBD approach, modified if

necessary, using additional data from the documents listed above. 

Work with, or bioassay sampling for, specific Am-241 materials is noted in ANL-E records,

including bioassay records. For Am-241 as a component of a plutonium mixture, the TBD notes

that ANL-E assumed that either none of the Pu-241 had converted to Am-241, or that all had

converted, and used the higher of the two for dose estimates, and suggests this method could be

considered in dose reconstructions. However, more realistic methods involving the application of

Am-241 ingrowth in the IMBA tool are also available, applying claimant favorable assumptions

for the age of the material for cases where this information is not available from records. 

Bioassay program procedures denoting specific accelerator-produced radionuclides are typically

not noted in the records, even for recent periods. This is not unexpected, given the wide variety of

radionuclides it is possible to produce. However, as noted above, analysis of at least 34 specific

radionuclides were included in bioassay analytical reports from 1953 through 1976, including

exotics such as protactinium and polonium in 1953 (SRDB Ref. ID 89280), neptunium in 1960

(SRDB Ref. ID 165282), and californium in 1974-1976 (SRDB Ref. IDs 16666, 16660, and

16656). Some of these reports specifically denote the radionuclides as accelerator related (e.g. Co57, Co-58, and Zn-65 identified in routine urine sampling associated with workers in the Building

D-211 cyclotron area in 1964, SRDB Ref. ID 165302, pg. 27-46). The records appear to indicate

that methods were implemented to assess risk from a variety of nuclides as the need arose. 

Guidance in the TBD will be modified or added where appropriate based on the available

information to aid dose reconstructors in interpreting mixtures of radionuclides. TBD will be

revised to provide dose reconstructors with additional definition, assumptions, and details as

outlined above, as well as any information derived from recent data capture and interviews, to aid

in assessment and interpretation of early bioassay records.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 3 of 23

ANL-E Finding 2 

2/13/2017

Status = Open

Potential Missed Dose from the use of Gross Alpha Counting for Bioassay (1946 to 1972)

Hughes, Lara, 3/8/2017

ANL-E provided gross alpha bioassay results from early operational periods which included

plutonium, americium, neptunium, thorium, actinium, and curium. Results below detection limits

were listed as zero. When results were positive, follow-up may have included analysis for specific

radionuclides. For example, SRDB 16712, pg 21-24, documents a plutonium intake incident

where the gross alpha results were followed up by a plutonium-specific analysis, noting that more

time and a larger sample size was needed for the latter analysis type. 

Missed doses are assessed based on the detection limits listed in the TBD (Table 5-11) for the

specific period, assessing the most claimant favorable nuclide, although a specific nuclide could be

assumed if the work records demonstrate occupational exposure to that specific nuclide (see

footnotes to the sampling results page for the example listed above, SRDB 16712 pg 23). The

earliest listed detection limit for the gross alpha analysis in the TBD is 0.4 dpm/1500 mL in 1948,

based on the lowest reported positive value in the records (note that recently obtained records

(SRDB 165285) demonstrate a lower value of 0.2 dpm/1500 mL in 1949-50); there is no

indication the procedure was different prior to this period. There is nothing further in the records

that indicates the effectiveness of the analyses was in question or considered unreliable based on

the factors mentioned in the finding. 

The finding that guidance is needed for interpreting results from the gross alpha analysis process is

valid, and clearer direction will be provided in the next TBD revision.

Lobaugh, Megan, 2/9/2018

Gross alpha analysis, also termed “fluoride insoluble” analysis, was used as a screening method to

evaluate exposure to several alpha-emitting radionuclides at once. Detection limits for early

periods are derived for the TBD using the lowest positive reported amounts found in ANL-E

records. Additional record acquisitions and records of previous DOE reported values are being

evaluated and will possibly result in refinements to these values. It is noted that a specific

procedure for analyzing plutonium may have existed separately from the gross alpha analysis

method prior to the earliest period described in the TBD (for example, SRDB Ref. ID 165282

includes a record for a Pu-239 result of <0.5 dpm/1500 mL for a urine sample in 1951, along with

a positive fecal sample result). 

Additional guidance will be provided in the TBD to direct dose reconstructors on how to interpret

bioassay data for gross alpha analysis. Current practice has been to apply the bioassay results to

all nuclides represented and use the most claimant favorable of the results unless the particular

radionuclide can be determined from the records. Based on the programmatic limitations of the

bioassay program for this period, this is considered adequate as a claimant favorable approach to

interpreting the results. 

It is noted that identification of specific nuclides is sometimes available from bioassay information

in ANL-E monthly program reports. This source of information will be further evaluated to 

determine if additional resources can be made available to the dose reconstructors (i.e., in addition

to the individual bioassay records provide by DOE) to identify the radionuclide of interest.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. SC&A would like to caution that the use of 

data obtained from gross counting of bioassay samples to project specific radionuclide intakes

(from an assortment of potential radionuclides) presents issues as outlined in SCA’s report for

Lawrence Berkeley National Laboratory [SC&A Evaluation of NIOSH White Paper, “Method to

Assess Internal Dose Using Gross Alpha, Beta, and Gamma Bioassay and Air Sampling at the

Lawrence Berkeley National Laboratory” SCA-TR-2018-SP003, Revision 0 (Draft), SC&A, Inc., 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 4 of 23

Vienna, Virginia. April 18, 2018.] 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 5 of 23

ANL-E Finding 3 

2/13/2017

Status = Open

Assumption of Default Inhalation Pathway May not be claimant favorable

Hughes, Lara, 3/8/2017

Ingestion intakes are considered as appropriate. Inhalation is the default intake mode for the 

NIOSH project (see ORAUT-OTIB-0060, section 3.2.1) because it is the most likely route of entry

in an occupational setting. Ingestion must be assigned in addition to inhalation when an intake is

based on air monitoring (OCAS-TIB-009), which is not the case for ANL-E assessments.

Ingestion would also be considered for known incidents, for which the route of exposure is

documented in bioassay program records (SRDB 165282, pg 3 and SRDB 165295, pages 42, 51,

56) and for acute intakes. Review of monitoring records indicates that route of intake for incidents

is noted in bioassay program reports and non-inhalation pathways are uncommon in comparison to

the inhalation pathway route. However, assuming intake by ingestion would not be a reasonable

assumption for missed dose because a constant chronic ingestion intake over an entire employment

period is not plausible. Finally, the example in the findings document suggesting that ingestion

can result in larger doses is not pertinent to NIOSH dose reconstructions, where annual, not

committed, doses are compared, and the document does not consider Type Super S, which would

further increase the dose from inhalation relative to ingestion for given bioassay results.

Buchanan, Ron, 4/4/2017

SC&A’s main emphasis in this finding was that the ingestion pathway should be considered along

with the inhalation pathway. SC&A’s example in their 2009 evaluation report was for one-year

(not 50-year committed doses), and was to illustrate that ingested dose should be considered along

with inhalation intakes in assigning annual doses. NIOSH indicated in their response that this is

done during dose reconstructions. SC&A finds this issue resolved and recommends closure. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 6 of 23

ANL-E Finding 4 

2/13/2017

Status = Open

Insufficient Information on the Calculation of Minimum Detectable Concentrations and Uncertainties in 

Bioassay Methodology

Hughes, Lara, 3/8/2017

MDCs are listed in the TBD based on all available information to date. Determination of MDCs 

becomes more difficult for earlier periods, where recorded MDCs are scarce or nonexistent, but

which may be inferred from the smallest recorded positive values or reported standard deviations

for sample results, as described in the TBD. Recent records from ANL-E are being reviewed to

determine if they may refine the current estimates of MDC in the TBD (for example, for uranium

analysis by fluorometry, the records in SRDB 165278, 165280, 165283, and 165297 clarify the

reporting units and show an earlier starting date than the current TBD lists). The assertion in the 

original finding that MDCs inferred by such methods may result in large assessed doses is correct,

but is an unavoidable aspect of the dose reconstruction process that is common to many sites.

Buchanan, Ron, 7/17/2017

From NIOSH’s BRS response of March 8, 2017, SC&A understands that the recent records from

ANL-E are being reviewed to determine if they may refine the current estimates of MDC in the

TBD. 

Lobaugh, Megan, 2/9/2018

From the review of previous and recently obtained records, it is likely that some refinements in

uranium and plutonium MDC values, and their applicable dates, can be made in the TBD. Further 

analysis of this data will be performed to evaluate whether modifications are possible for MDCs

and/or uncertainties of other nuclides as well.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 7 of 23

ANL-E Finding 5 

2/13/2017

Status = Open

Lack of Guidance for Estimation of Missed Dose for Unmonitored Workers 

Hughes, Lara, 3/8/2017

Records from the earliest periods at ANL-E are available and indicate that individuals working in

radiological areas were monitored for internal and external exposure. With the establishment of

ANL-E came the establishment of a health physics program and a medical department. Naturally

the program would ramp up and new methods would be developed and implemented as time

progresses. The earliest bioassay seen in files is from mid-1945. 

The potential need for assignment of unmonitored dose is still being assessed.

Lobaugh, Megan, 2/9/2018

According to ANL-E records and interviews with former workers and radiological program

personnel (SRDB Ref. ID 12632), all employees in radiologically controlled areas were

monitored; external dosimetry reports, bioassay results, and information in ANL-E monthly

reports appear to confirm this. Review of 95 claims with employment dating back to 1946 and

extending to 2008 revealed only three claims with no internal or external monitoring, with either

short-duration employment (<3 months) or job titles consistent with non-radworkers. Therefore,

information from environmental reports incorporated as internal environmental intakes in

ORAUT-TKBS-0036-4 are most appropriate for unmonitored workers outside of radiologically

controlled areas. These values would be considered overestimating since they include

contributions from fallout for early years in addition to potential intakes from ANL-E operations.

ORAUT-TKBS-0036-5 will be revised to direct the use of environmental intakes from ORAUTTKBS-0036-4 to clarify this.

Buchanan, Ron, 5/1/2018

SRDB Ref. ID 12632 is a very lengthy document (347 pages) that covers many documents,

decades, and situations. It would be helpful in verifying NIOSH’s statement that “all employees in

radiologically controlled areas were Monitored” if NIOSH could provide page numbers in that

document that provides support for that conclusion. Additionally, SC&A will review the revised

TBD when released. 

Lobaugh, Megan, 6/21/2018

This post is in response to the request for page numbers in SRDB 12632, which is referenced in

the NIOSH response. For that document, NIOSH specifically is referencing pages 11, 18, and 24. 

In addition to the document referenced, interviews with past workers also corroborate the

statement that "all employees in radiologically controlled areas were monitored": SRDB 70777 p.

4 and 5; SRDB 167633 p. 6; SRDB 167826 p. 6; SRDB 167827 p. 7; and SRDB 167842 p. 6 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
 

Page 8 of 23

ANL-E Finding 6 

2/13/2017

Status = Open

Failure to Adequately Define and Assess Occupational Medical Exposures in the Pre-1988 Years and

Potentially Misses Special Employment Exams

Hughes, Lara, 3/8/2017

ORAUT-OTIB-0006 has been revised (in 2011) since the original SC&A review and the last

revision of the TBD. The ANL-E Medical TBD will be evaluated and revised as necessary to

incorporate ORAUT-OTIB-0006 recommendations regarding special screening exams.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 9 of 23

ANL-E Finding 7 

2/13/2017

Status = Open

Lacking Techniques and Protocols for Medical Examinations prior to 1988 Increases the Uncertainty of DCFs

listed in ORAUT-TKBS-0036-3 

Gogliotti, Rosanna, 2/13/2017

In Finding 7 and Secondary Issues 3 and 4, SC&A was concerned with the lack of knowledge of

the type of X-ray equipment used at ANL-E prior to 1988, along with the beam quality,

calibration, protocols, and techniques used for dose calculations. Since ORAUT-TKBS-0036-3

references ORAUT-OTIB-0006, Revision 03 for this information, and SC&A has reviewed and

approved this document, including the information pertaining to equipment, the doses derived

from these assumptions are claimant favorable. Therefore, SC&A recommends closing Finding 7.

Hughes, Lara, 3/8/2017

NIOSH concurs with SC&A's recommendation to close this finding. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 10 of 23

ANL-E finding 8 

2/13/2017

Status = Open

Frequencies and Types of X-ray Exposures Are Uncertain

Gogliotti, Rosanna, 2/13/2017

As was previously mentioned, some of the PFG doses have changed from Revision 03 to Revision

04 of ORAUT-OTIB-0006; therefore, ORAUT-TKBS-0036-3 needs to be updated. In ORAUTTKBS-0036-3, NIOSH recommends assigning PFG doses for the years 1946 to 1956. SC&A

suggested that dose assignment from PFGs should extend to 1958. At the time the site profile

review was written, SC&A referenced Januska and Smith 1961, which suggests that the equipment

used through December 1958 would be capable of photofluoroscopy. In Attachment 4 of SC&A’s

2009 site profile review, SC&A and NIOSH both respond to this issue, but it is not part of a

formal issues resolution process. Therefore, the issue of PFGs is raised in Finding 8 and SC&A

recommends that this finding remain open for discussion.

Hughes, Lara, 3/8/2017

Any new information collected from ANL-E since the original TBD was written will be

incorporated in a revision. ORAUT-OTIB-0006 has been revised (in 2011) since the original

SC&A review and the last revision of the TBD. Note that the 1961 Januska and Smith reference 

(SRDB 76496) mentioned by the finding states that the diagnostic X-ray facility was designed ‘for

diagnostic work using radiographic and fluoroscopic methods’ and that ‘approximately 80 percent

of the studies made consist of posterior-anterior chest radiographs in conjunction with annual

recheck, pre-employment, and termination physical examinations.’ Nothing in the document that

provides information on whether PFG exams were still performed or when they may have

terminated. 

The review of x-ray records in claimant files showed that PFG was rarely found after 1948, and

was found only in conjunction with medical examinations that were performed at the University of

Chicago. PFG examinations were only found through 1956 in a review of claimant files. The xray information in the ANL-E claim file records constitute a body of evidence that should be used

in the TBD. ORAUT-OTIB-0006 should be used in the absence of such evidence. 

Buchanan, Ron, 7/17/2017

SC&A understands this statement to indicate that ORAUT-TKBS-0036-3 will be revised to 

incorporate the revisions in Revision 04 to ORAUT-OTIB-0006, and, until then, the dose

reconstructor is to use the current version of ORAUT-OTIB-0006. 

Lobaugh, Megan, 2/9/2018

Pertinent information from ORAUT-OTIB-0006 will be incorporated in the ANL-E TBD, as

stated above. 

Evaluation of claimant files supports the SC&A concern that post-1980 X-rays may have been

implemented more frequently than every four years. TBD will be revised to assume annual Xrays, rather than at four-year intervals, be applied for workers with no available X-ray records. 

Claimant files and other record information will be evaluated to determine whether the ending date

for the application of PFG exam should be extended from 1956 through 1958.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 11 of 23

ANL-E Finding 9 

2/13/2017

Status = Open

Uncertainty and Undocumented Aspects of the Film Dosimetry Need Re-examination

Hughes, Lara, 3/8/2017

Further research into dosimeter characteristics will be performed to evaluate the similarity of

ANL-E dosimeters to those used at INL and used for ANL-W workers and the validity of the

under-response assumptions in the TBD.A simplifying table will be developed to aid dose

reconstructors in application of dosimeter parameters. Since the 2009 SC&A evaluation, the ANLE workbook has been revised to reflect the guidance and parameters of the current TBD.

Lobaugh, Megan, 2/9/2018

To date, no additional information has been identified from recently captured documents or from

interviews with former ANL-E employees that is expected to significantly modify or enhance the

current descriptions in the TBD. Review efforts will continue to identify more detailed

specification information for film and neutron dosimeters for early time periods, including

evaluating the need for additional data capture.

Buchanan, Ron, 5/2/2018

SC&A will review the additional data and/or revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 12 of 23

ANL-E Finding 10

2/13/2017

Status = Open

Neutron Dosimetry is Inadequately Addressed

Hughes, Lara, 3/8/2017

NIOSH concurs that improvement on the guidance on neutron monitoring is needed. Any new

information collected from ANL-E since the original TBD was written will be incorporated as

applicable. For periods prior to the implementation of neutron dose monitoring (1953), or when

neutron films were only read when the gamma dose was above 100 mrem (before 1960),

evaluation of appropriate neutron to photon ratios for the reactor types in use at ANL-E would be

suggested. Additional data evaluation is needed.

Lobaugh, Megan, 2/9/2018

To date, no additional information has been identified from recently captured documents or from

interviews with former ANL-E employees that is expected to significantly modify or enhance the

current descriptions in the TBD. Review efforts will continue to identify more detailed

specification information for neutron monitoring. 

It is noted that prior to 1961, there is little evidence of the routine use of neutron monitoring

dosimeters. SRDB Ref. ID 12632 indicates that surveys were performed prior to 1960 using

neutron survey instruments, but that neutron doses were not recorded from these. 

The earliest record found in a review of claimant files of an NTA film result was from June of 

1957, which is consistent with the TBD information that it was in use by 1956. There are annual 

dose summary sheets occasionally found which record neutron doses of zero for earlier years than

this, but these are not supported by records of actual dose reports. 

NIOSH will continue efforts to locate and evaluate ANL-E records to develop neutron to photon

ratios from available monitoring data, as well as other methods of addressing these deficiencies

(e.g., adopting appropriate ratios from sites with similar facilities, see comment below) and will

update the TBD information accordingly. Additional data capture efforts targeted at film and

neutron dosimeters specifications for early periods may be warranted. 

For periods prior to the implementation of neutron dose monitoring (1953), or when neutron films

were only read when the gamma dose was above 100 mrem (before 1960), it is suggested that the

glovebox neutron to photon ratio developed for Hanford could adequately describe plutonium

glovebox work at ANL-E. Since this ratio is more claimant favorable than N/P ratios for reactors

at Hanford, it would be expected to overestimate neutron doses from sources at ANL-E (primarily

test reactors and plutonium gloveboxes) for these periods.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 13 of 23

ANL-E Finding 11

2/13/2017

Status = Open

Quantification of External Exposures to Unmonitored Workers Outdoors is Inadequately Justified

Gogliotti, Rosanna, 2/13/2017

For time periods prior to 1972, there are virtually no data characterizing the external radiation

fields outdoors. This finding has to do with remaining concerns SC&A has pertaining to the

quality of data used to support the method used to estimate dose to outdoor unmonitored workers.

Further description of this finding can be found on pages 47–49 of SC&A’s 2009 review. This

finding still needs to be addressed in its entirety by NIOSH.

Hughes, Lara, 3/8/2017

No additional records have been identified which provide ambient on-site external exposures prior

to the period currently described in the TBD (i.e., before 1972). For the period when monitoring is

available, it is concluded that “unbadged workers would not be expected to receive a dose in

excess of the normal background dose of 100 mrem/yr” which was determined to be the average

annual dose measured at off-site locations not influenced by site operations (SRDB 14459, pg 55,

SRDB 14461, pg 57). For the period prior to 1972, use of the average values for other DOE sites

in ORAUT-PROC-0060 (Occupational Onsite Ambient Dose Reconstruction for DOE Sites) may

be applied as an overestimating assumption since the doses average doses in that document exceed

those at ANL-E for concurrent time periods.

SC&A finds that there should be more detailed information concerning the use of the average

values for other DOE sites from ORAUT-PROC-0060 included in the ANL-E ORAUT-TKBS0036-4 TBD document to ensure consistent application in dose reconstruction.

Buchanan, Ron, 7/17/2017

Lobaugh, Megan, 2/9/2018

Current estimates of ambient external dose from ORAUT-TKBS-0036-4 are based on 

overestimates of airborne exposure to short-lived, gamma emitting nuclides, primarily Ar-41 from

the CP-5 reactor releases since onsite measurements of direct radiation based on TLD monitors 

were indistinguishable from offsite measurements given the uncertainty of the results. The 

maximum external dose currently assigned for non-monitored workers based on these values is

0.014 rem per year (assumed to be 2600 hours). By contrast, the average value of the maximizing

onsite ambient doses from the sites listed in ORAUT-PROC-0060 range from around 0.150 rem in

1971 up to 2.7 rem in 1946. Because these values would likely be comparable to, or exceed,

average external doses for monitored workers at ANL-E for the same periods, they would be

anticipated to be very claimant favorable estimates of doses to non-monitored workers. These 

ORAUT-PROC-0060 values, or more reasonable estimates, if they can be derived, will be

incorporated in the TBD direction to dose reconstructors.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 14 of 23

ANL-E Finding 12

2/13/2017

Status = Open

Outdoor Inhalation Exposures Associated with Waste Disposal Operations In Area A and From Particulates

Released During Accidents are not Adequately Addressed

Gogliotti, Rosanna, 2/13/2017

Our review reveals that NIOSH’s conclusions about this matter are reasonable; however, some

additional discussion is needed regarding the potential for short-term, but possibly large, inhalation

exposures associated with the waste disposal operations in Area A and whether exposures to

particulates that might have been released during accidents could have contributed significantly to

the outdoor inhalation dose. Additionally, some discussion is needed about the exposures that

some workers may have experienced during accidents where large amounts of radionuclides might

have been released to the atmosphere over short periods of time. Further description of this finding

can be found on pages 49–50 of SC&A’s 2009 site profile review. This finding still needs to be

addressed by NIOSH.

Hughes, Lara, 3/8/2017

The finding states that the conclusion in the TBD (that the potential for inhalation exposure to

particulates outdoors in Site A up to 1954 was negligible) is reasonable, but that additional

discussion is needed regarding the potential for short-term, but possibly large, inhalation

exposures associated with the waste disposal operations in Area A. 

According to the TBD (ORAUT-TKBS-0036-2, Section 2.2.2), waste disposal operations at Site A

were conducted from 1943 through 1949, with buried waste removed to Site D in 1949;

consequently, all waste disposal operations at Site A were conducted during the period prior to

1954 when the TBD assumptions were considered to be adequate.

Buchanan, Ron, 7/17/2017

SC&A finds that NIOSH’s response was supported during the visit to ANL-E on March 21, 2017,

and recommends closing the issue. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 15 of 23

ANL-E Finding 13

2/13/2017

Status = Open

Lack of Consideration of Occupational Radiological Exposure at Site A and Plot M.

Gogliotti, Rosanna, 2/13/2017

In the Attachment 4 NIOSH responses on page 91 of SC&A’s 2009 site profile review, NIOSH

indicates that these facilities are part of the Metallurgical Laboratory (Met Lab) and will be

addressed outside of the ANL-E TBD. There is currently no Met Lab TBD; however, SC&A

located an internal guidance document that instructs dose reconstructors how to perform a dose

reconstruction at the site (NIOSH 2012). This guidance document makes no mention of Plot M

and only a vague mention of Site A. SC&A confirmed that the Met Lab covered periods begin in

1942, earlier enough to cover Site A and Plot M; however, SC&A recommends that this issue be

transferred to the Board work group that oversees Met Lab so that this finding can be addressed in

that forum. 

Hughes, Lara, 3/8/2017

Site A and Plot M employment would be covered under the Metallurgical Laboratory site

designation until June 30, 1946 and under the ANL-E site designation starting July 1, 1946. The

operations at Site A and Plot M are discussed in the Site Description document. There does not

seem to be an issue assigning claims to the respective site (Met Lab vs. ANL-E) by DOL based on

claim review by NIOSH.

Buchanan, Ron, 4/4/2017

SC&A’s main emphasis of this finding was to ensure that the workers at Site A and Plot M were

included in the Met Lab SEC through June 30, 1946. According to NIOSH’s recent reply this is

correct; therefore, SC&A finds this issue has been resolved and recommends closure. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 16 of 23

ANL-E Secondary Issue 1

4/7/2017

Status = Open

Potential Missed Dose from Skin and Clothing Contamination

Buchanan, Ron, 4/11/2017

SC&A Update: Since issuance of the original ANLE TBDs, NIOSH has addressed this issue in a

number of venues and has developed a protocol for assigning skin dose, not only for direct

deposition on skin (as provided in ORAUT-OTIB-0017, Revision 01, Interpretation of Dosimetry

Data for Assignment of Shallow Dose), but also for contaminated clothing. On this basis, SC&A

finds that this issue can be readily resolved by a revision to ORAUT-TKBS-0036-6 for ANL-E

that makes appropriate reference to this guidance for reconstructing beta exposure of skin from

direct deposition and clothing contamination.

Hughes, Lara, 4/24/2017

The TBD will be evaluated and revised to incorporate appropriate language to address dose

reconstruction in accordance with OTIB-0017 from skin and clothing contamination.

Lobaugh, Megan, 2/9/2018

TBD revision will incorporate appropriate guidance from, or reference to, ORAUT-OTIB-0017 in

assessing doses from skin and clothing contamination.

Buchanan, Ron, 5/2/2018

SC&A will review the revised TBD when released. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 17 of 23

ANL-E Secondary Issue 2

4/7/2017

Status = Open

Other Potential Medical Exposures Have Not Been Identified

Buchanan, Ron, 4/11/2017

SC&A Update: SC&A raised the issue that ANL-E workers could have been exposed to radiation

from medical equipment other than X-rays. During the worker interviews summarized in

Attachment 3 of SC&A 2009, it seems clear that this was not a possibility. Attachment 3 states:

“There are no teletherapy units or radiation generating devices in the medical department except

the x-ray units. There has been no administration of radioactive material for diagnostic or

therapeutic reasons.” Therefore, SC&A recommends closing Observation #2 (Secondary Issue 2).

Hughes, Lara, 4/24/2017

NIOSH concurs. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 18 of 23

ANL-E Secondary Issue 3

4/7/2017

Status = Open

Additional Factors Contribute to Medical Dose Uncertainties 

Buchanan, Ron, 4/11/2017

SC&A Update: As with the X-ray equipment, ORAUT-TKBS-0036-3 references ORAUT-OTIB0006, Revision 03 for this information, and SC&A has reviewed and approved this document,

including the information pertaining to assignment of uncertainty. Therefore, the doses derived

from these assumptions are claimant favorable. SC&A recommends closing Observation #3

(Secondary Issue 3).

Hughes, Lara, 4/24/2017

NIOSH concurs. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 19 of 23

ANL-E Secondary Issue 4

4/7/2017

Status = Open

Internal Dose to Workers from Radon Exposures is Not Considered

Buchanan, Ron, 4/11/2017

ANL-E handled Ra-226, Ac-227, and Th-230 as part of R&D and other activities. SC&A is

concerned about the lack of consideration of doses from the unmonitored gaseous radionuclides

such as thoron, actinon, and radon.

No records have been identified which indicate worker monitoring for radon was routinely

performed; however no major sources of enhanced radon exposure have been identified for the

ANL-E site. There were no large quantities of uranium or radium in ore stored or handled at ANLE. 

Hughes, Lara, 4/24/2017

No records have been identified which indicate worker monitoring for radon was routinely

performed; however no major sources of enhanced radon exposure have been identified for the

ANL-E site. There were no large quantities of uranium or radium in ore stored or handled at ANLHughes, Lara, 4/24/2017

E. 

Buchanan, Ron, 7/17/2017

SC&A finds that there were opportunities for exposure to radium 226 (Ra-226), actinium 227 (Ac227), and thorium. In fact, the ANL-E TBD acknowledges that the site used Ra-226 in Buildings

203 and 211 as part of the accelerator program. In Building 200, radon-200 was produced

(ORAUT-TKBS-0036-2, Revision 00 PC-1, Table 2-2). Furthermore, there was a substantial

incident involving rupture of an Ra-226 source that generated radon issues through time. Thorium

was machined in the East Area and handled in research and development (R&D). Ac-227 was also

handled in R&D (Manning 1950). Given the use of radium, actinium, and thorium at ANL-E,

further investigation into potential occupational exposures to radon and possibly thoron and

actinon are necessary.

Lobaugh, Megan, 2/9/2018

Radon filter traps were used for radium work in New Chem building and at Site A as early as 1948

(SRDB Ref. ID 16426, p.13, SRDB Ref. ID 16427, pg. 5, SRDB Ref. ID 16426, p.17). In addition,

air sampling that found elevated levels of radon indicated a radium source leak in 1949, as noted

above (SRDB Ref. ID 16427, pg. 22). This would indicate that protective measures were

implemented from early operations for anticipated high exposures from radon. While more recent 

environmental reports show monitoring and reporting of offsite radon releases, no additional

information has been located describing onsite routine radon monitoring programs. Recent 

interviews with former ANL-E workers indicated that air monitoring was routine, but no specific

monitoring related to radon was recalled. While additional research into radon exposures will

continue, no changes to the current method of assessing radon intakes in TKBS-0036-4, section

4.4, is anticipated.

Buchanan, Ron, 5/2/2018

In evaluating this issue it would be helpful to know if NIOSH has located any bioassay data for

radium and/or its decay products in the NOCTS files they have evaluated; such as the 95 claims

previously referred to in Finding 5. If workers were bioassayed for radium and its decay products

this would indicate that there was potential exposure from radon and it decay products.

Lobaugh, Megan, 6/5/2018

Records obtained from ANL-E include over 800 bioassay sample results for radium (many of

which were positive) between 1949 and 1979. These included urine and fecal samples and were

identified as either Ra-223, Ra-226, or simply ‘radium’. However, to date, documentation

contains insufficient information to identify chemical/physical forms, quantities, or processes in

which radium was encountered, although a few isolated incident reports have been found. NIOSH 

concurs that activities with radium could indicate potential exposure to radon and radon decay

products, but as previously noted, has not found evidence of routine worker monitoring for radon 

exposure. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 20 of 23

At this time, NIOSH is not proposing any changes to the current methodology. Currently, radon

doses are assessed in Section 4.4 of ORAUT-TKBS-0036-4 (Environmental Dose). Justification 

for not assigning additional radon dose, aside from environmental dose, will be included in

ORAUT-TKBS-0036-5 (Occupational Internal). See previous BRS responses for more

information. If additional information regarding radon exposures or monitoring is found during

the process of updating the TBDs, it will be assessed and included. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 21 of 23

ANL-E Secondary Issue 5

4/7/2017

Status = Open

Lack of Treatment Provided to the Monitoring of Contractors, Transferees, and Visitors

Buchanan, Ron, 4/11/2017

Although “Rover Dosimeters” are mentioned, there is scant mention in the site profile of the

monitoring of visitors, transferees, and contractors. Of particular concern, is the absence of

information on the treatment of contract workers during the numerous D&D activities known to

have been conducted at ANL-E. Since this issue has been a concern at other sites, it should be

addressed in greater depth here.

Hughes, Lara, 4/24/2017

There is no information in records from ANL-E suggesting that contractors, transferees, or visitors

would not have been monitored in accordance with applicable procedures. While no specific

programmatic or policy information has been located regarding contractors, transferees, or visitors,

records support that operations in radiologically controlled areas were conducted primarily by

ANL-E employees (i.e. visitor or subcontractor entry in controlled areas would have been

infrequent). Records further document that non-employee and transferred employees were

monitored as needed (internal monitoring for a “transferee” occurring in 1951 (SRDB 165307, pg.

17), external monitoring for “visiting personnel” in 1954 (SRDB 165316, pg. 5), and internal

monitoring for visiting personnel (Bioassay Program Report, SRDB 165293)).

Buchanan, Ron, 7/17/2017

SC&A finds that the details of visitor and subcontractor monitoring are lacking. According to page

51 of ORAUT-TKBS-0036-6, rover dosimeters were pocket ionization chambers (PICs) that were

not permanently assigned and were typically worn by visitors or personnel who were not normally

assigned to an area. Would these PIC doses be recorded for visitors from other DOE facilities, and

for the ANL-E workers? The Site Research Database (SRDB) references provided by NIOSH

were for the early years at ANL-E, but the majority of the decontamination and decommissioning

work would have occurred in later years, perhaps by subcontractors. Have radiation work permits,

or similar job plans, been searched for monitoring compliance, especially for subcontractors?

Lobaugh, Megan, 2/9/2018

While no documentation has been found describing formal policy or contractual relationships

involving radiation protection policy regarding contract workers, early monthly reports document

that contractor company workers were included in monitoring (see for example, SRDB Ref. ID

16424 (1948), page 16, and SRDB Ref. ID 145772 (1952), pages 25, 26, 41, and 50). SRDB Ref. 

ID 145772, page 59, also describes visitors included in monitoring at the site. Transferees are also

designated in ANL-E monthly reports and other documents (see SRDB Ref. IDs 165278, 165280,

165283, and 165297). Interview with former ANL-E workers (earliest employment date 1947)

verified that contractors were not typically used for work in radiological areas, but that all

individuals in these areas were monitored (SRDB Ref. IDs 167633, 167826, 167827, 167842).

Consequently, there is no indication that visitors, contractors, or transferees would have been

excluded from appropriate radiation protection or monitoring procedures.

Buchanan, Ron, 5/2/2018

SC&A reviewed recent interviews and related documents and did not find evidences of 

subcontractors and visitors being monitored differently than ANL-E employees. Therefore, SC&A

recommends closure of this issue. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
 

Page 22 of 23

ANL-E Secondary Issue 6

4/7/2017

Status = Open

Human Radiation Experiments Not Addressed

Buchanan, Ron, 4/11/2017

ANLE and its predecessor, the Metallurgical Laboratory, participated in human radiation

experiments, including some involving employees. For example, six Metallurgical Laboratory

employees volunteered to drink a solution with small amounts of plutonium. If exposure due to

human radiation experiments should be included in the dose reconstruction, the TBD would

benefit from inclusion of information related to these experiments. SC&A also has concerns if

participation in experiments of that nature would be included in the energy employees’ medical

files; further research on this issue would be needed to determine if medical experiment

participation is available and provided with employee medical files, and if this will be included in

dose reconstruction. 

Hughes, Lara, 4/24/2017

Doses received from participation in human radiation experiments are considered covered

exposure under EEOICPA, however they typically have not been addressed in site technical basis

documents. These doses would be assessed at an individual level based on the information that is 

available in the documentation (e.g. SRDB 31911 and 33842)

Buchanan, Ron, 7/17/2017

SC&A finds that while the ANL-E TBDs briefly mention human experiments, they do not

explicitly instruct the dose reconstructor to include the doses and where to find the details of some

of the human experiments. SRDB Ref. ID 33842, pages 127–147, provides a detailed list of 43

human experiments conducted at ANL-E and should be referenced in the internal dose TBD to

provide further information for dose reconstruction. Additionally, SC&A has not seen verification

that doses from the human experiments were calculated, recorded, and available in the

participant’s records.

Lobaugh, Megan, 2/9/2018

Revised TBD will include explicit direction to dose reconstructors that doses from human

radiation experiments are covered exposures to be included in the assessments, and will cite

references providing additional information. 

Note that the facility referred to in the SC&A discussion (from SRDB Ref. ID 33842, pages 127-

147) is the University of Chicago – Argonne Cancer Research Facility; this is described as a

separate facility from ANL-E (SRDB Ref. ID 31911, page 63) and is not included as a covered

facility under EEOICPA or described in the ANL-E TBDs; the studies described for this facility

were on patients of that facility or the Chicago Lying-In Hospital, or inmates of the Illinois State

Penitentiary, and not on employees of ANL-E. Studies related to the ANL-E facility are described

on pages 5-13 of SRDB Ref. ID 33842; these studies described the involvement of both patients

and employees; several of these studies are prior to the period in which the ANL-E facility is

covered under EEOICPA. 

Buchanan, Ron, 5/2/2018

SC&A concurs with NIOSH’s explanation and will review the reviewed TBD when release. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.
Page 23 of 23

ANL-E Secondary Issue 7

4/7/2017

Status = Open

Incidents and Accidents Need to be Reexamined 

Buchanan, Ron, 4/11/2017

Exposure conditions that may present themselves during an incident or occurrence have not been

addressed in the TBD. Although individuals involved in incidents are usually monitored, the

incident itself may pose special exposure conditions that need to be considered in the dose

reconstruction (e.g., injection versus inhalation; partial body exposure to an external beam;

cleanup of a spill involving nontraditional radionuclides).

Hughes, Lara, 4/24/2017

Significant incidents and accidents are outlined in Section 2.4 of the site description TBD for

ANL-E, with further detail provided in the 1979 Draft Environmental Impact Statement (SRDB

17809). 

Additional records obtained indicate that radiological incidents are documented at least as early as

1950 in ANL-E program reports (SRDB 16712, 165264, 165293-165296, 165303, 165304,

165307), special incident reports (SRDB 165261, 165274) and monitoring records for individuals

(SRDB 165278, 165280, 165283, 165297). Results of monitoring associated with these incidents

would be included in individual monitoring records provided by DOE in support of EEOICPA

dose reconstructions. 

Buchanan, Ron, 7/17/2017

SC&A finds that these reports only cover accidents during the early period at ANL-E; i.e., pre

1979. Similar research needs to be conducted for 1979 and forward. 

Lobaugh, Megan, 2/9/2018

Review of records has identified ANL-E documentation of minor incidents (spills, contamination,

etc.) after 1979, but no compilation or description of major accidents. However, ANL-E

documentation demonstrates that even in early periods, exposures associated with significant

incidents are noted as such in records. Because major incidents would likely have been tracked by

DOE on a site-wide basis during the later period in question, no revision or additions to this

section are considered necessary to aid in dose reconstructions.

Buchanan, Ron, 5/2/2018

SC&A recent search for incidents at ANL-E did not result in any specific documentation of major

incidents that would indicate unmonitored exposures. As at other DOE sites, incidents will be

handled on any individual bases during dose reconstruction. Therefore, SC&A recommends

closure of this issue. 

NOTICE: This report has been reviewed to identify and redact any information that is 

protected by the Privacy Act 5 USC §552a and has been cleared for distribution.